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Your Privacy is Important to Us

Last Updated: 06-05-2019

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Postmedia Network Canada Corp. and its affiliated and subsidiary entities, including Postmedia Network Inc. (“Postmedia ”, “we” or “us”) are committed to protecting your privacy and safeguarding your Personal Information (as defined below) we always strive to be transparent about the data we collect about you, how it is used and with whom it is shared. The Postmedia Privacy Policy (available here) and this Privacy Statement (collectively, the “Privacy Policy”) describe how we may collect, use and disclose Personal Information of subscribers, customers, site visitors, etc. (collectively “you” or “Users”). The Privacy Policy applies to all Postmedia websites, applications, and services (each a “Property” or, collectively, “Properties”). These Properties may be subject to change from time to time in Postmedia’s sole discretion.

In this Privacy Policy, you will also see references to “Customized Experiences” which describe content, advertising, and offers (including third party sponsors or advertisers) that are tailored to you based on information that we’ve collected from your interactions with our Properties.

By visiting our Properties, subscribing to our services or submitting your Personal Information for any reason, you signify your agreement to the terms and conditions of this Privacy Policy.

Postmedia may modify this Privacy Policy and, if we make material changes to it, we will provide notice to you (at www.postmedia.com, by email or both), to provide you with the opportunity to review the changes before they become effective. If you object to any changes, you may close your account or unsubscribe. You acknowledge that your continued use of our Properties after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your Personal Information is subject to the updated Privacy Policy.

This Privacy Policy does not apply to personal information that we collect, use or disclose for journalistic purposes. It does not cover information that is not personally identifiable, such as anonymous or aggregated data, which cannot be associated with a specific person (“Non-Personal Information”). Non-Personal Information may include, without limitation, information about when and how Users interact with our Properties, demographic statistics about our Users, IP addresses, geolocation information, unique device identifiers, browser type, browser language and other transactional information. This information is typically used by Postmedia, its advertisers or audit bureaus.

INFORMATION WE COLLECT

What Types of Information Do We Collect?

“Personal information” means information that can be used to identify an individual. Examples of Personal Information that we collect, use and disclose (as further set out in the “To Whom Do We Disclose Personal Information” section below) include your contact information (name, address, phone number or email address) and billing information (credit card number or banking information). Personal information does not include publicly available information. In most cases, we collect Personal Information when you purchase or subscribe to a product or service that we offer. Occasionally, we may also collect Personal Information from a third party based on your consent or as otherwise permitted by law.

Non-Personal Information, as defined above; and

Public Activities Information: means information gathered based on actions that you take on our Properties that are designed to be visible to other Users, such as comments or recommendations

When Do We Collect Personal Information?

We collect Personal Information when you provide, post or upload it to us or one of our Properties, such as, without limitation, when you fill out a form, post a comment or subscribe to a newspaper.

Using log-ins, cookies, device information and internet protocol (“IP”) addresses, we identify you and log usage data when you visit our Properties, such as when you view or click on content or ads, perform a search, install or update one of our mobile apps, or share articles.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Properties and devices. We also allow third parties to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also opt-out of our use of cookies and similar technologies that allow third parties to track your behavior.

Why Do We Collect Personal Information and How Do We Use It?

We identify the purposes for which we may collect, use and disclose your Personal Information at the time that you provide such information to us. Consent is also secured when we collect your Personal Information, except where permitted or required by law.

send messages about the availability and methods of use of our products, services and Properties, as well as with respect to, security or other service-related issues. Please note that you may change your communication preferences at any time but you cannot opt-out of receiving service messages from us, including security and legal notices;

provide network updates, reminders, and promotional messages from us and our partners;

conduct research for the further development of our Properties in order to provide you and others with a better, more intuitive and personalized experience, as well as to drive growth and engagement on our Properties;

investigate, respond to and resolve complaints and service issues (e.g., bugs);

produce and share aggregated insights using Non-Personal Information. For example we may use your data to generate statistics about our Users, to calculate ad impressions served or clicked on, or to publish User demographics for a Property; and

target (and measure the performance of) ads to Users both on and off our Properties, directly or through a variety of partners, using the following data, whether separately or combined:

Data from advertising technologies on and off our Properties, like web beacons, pixels, ad tags, cookies, and device identifiers;

User-provided information (e.g., profile, contact information);

Data from your use of our services, products and Properties (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.);

Information from advertising partners and publishers; and

information inferred from data described above.

The manner in which we use your Personal Information will depend on which products you use or Properties you visit, how you use those products and the choices you make in your settings. With the assistance of automated systems and using digital inferences, we use the data that we collect to personalize our Properties so that they can be more relevant and useful to you.

EXAMPLES OF TYPES OF INFORMATION COLLECTED, STORED AND USED

Registrant and Subscriber Information

We collect contact information to communicate or deliver products and services.

You may register or enhance your Postmedia profile by linking your Facebook or Google accounts to Postmedia Properties. In doing so, you are authorizing Facebook and/or Google to send Postmedia certain information from those social media accounts (Facebook/Google), and you are authorizing Postmedia to collect, store, and use what is sent in accordance with this Privacy Policy.

Linking social media sites to our Properties will result in our collection of your IP address. We will also have visibility to the page you are visiting on our Property and may set a cookie to enable the linking to function properly.

Billing and Credit Card Information

Collecting billing information for payment of purchases of Postmedia’s products and services.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Name

Credit Card Details

Billing Addresses

Processing payments for fees owed for subscriptions

Providing Customized Experiences for improved billing & processing.

Billing and credit card information is subject to our Terms of Service. You are responsible for supplying and maintaining accurate information for your account, paying all fees owed, and reasonably managing the security of your account (including any applicable login and password information). Should you fail to meet these obligations, Postmedia may, in its discretion, suspend or terminate your account and refuse future use of our products and services.

Contests, Sweepstakes and Special Offers

Contact information collected to determine eligibility for, and participation in, any products and services, including delivery of any awards or rewards.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Name

Mailing Address

Telephone Number

Age / Date of Birth

Newsletter Subscription Consents

Public activities as conditions of participation

Delivering awarded products or services as required by the applicable terms of the offer or contest.

Determining eligibility for participation such as, for example, whether a participant lives in an eligible area for participation in an offer or contest.

Verifying that a participant is old enough to participate.

Registering participants for further opportunities upon receiving their consent.

Public activities that are conditions of participation such as socially sharing or reviewing material

Postmedia may occasionally collect personal opinions or responses from you when you participate in sweepstakes, contests or special offers, which information may be shared with a third party, in an anonymized or aggregated fashion. We will notify you, in a clear manner, at the time of collection, if this information will be shared.

No purchase is necessary for participation in any of our contests.

Reader Surveys, Reader Panels and Market Research

Collection of Personal Information for voluntary participation in surveys conducted by or via Postmedia.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Name

Mailing Addresses

Telephone Number

Age or Date of Birth

Gender

Marital Status

Interests

Household Composition, Income & Expenditures

Personal Opinions

Newsletter Subscription & Consents

Purchase Intent

Customer Service Related Inquiries

Location Preferences

Job Industry

Job Title

Social Identity

Publicly Available Social Profiles

Newsletter Subscription & Consents

Understanding your experience with our products and services in order to develop improved offerings.

Providing a Customized Experience

Data is collected by Postmedia on the phone or by mail, email, the Internet or in person. Non-Personal Information collected in this manner may be shared with advertisers and partners.

Customer Service

Contact information and recordings to better assist you when you request help from our customer support service.

Some of our Properties deliver content based on your current or historical location, if you choose to enable sharing of your location data with Postmedia. We store that information both locally on your device and on our servers. If you do not enable location sharing, the Property will not share this information with us and we will not collect or store your current or historical information. We also collect Non-Personal Information of location information that does not request your consent before collection.

Readership Behaviour

Information on what you read and how you interact with content on our Properties in order to provide you with related Customized Experiences and for advertising purposes.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Articles and Topics Read

Tools and Systems Interacted With

Providing recommendations for further reading based on articles and topics read previously. For example, a User who reads many sports articles may find that related stories offered at the bottom of a web page feature additional content involving sports.

Providing recommendations for content based on tools previously used by a User. For example, we may recommend using Postmedia’s financial stock watching tools to users who have used any of the investment-related tools on our Properties.

Providing more customized advertising targeted towards a user’s interests. For example, Postmedia may display ads for a particular brand of vehicle after a user reads a number of articles on that particular brand of vehicle.

Conferences and Live Events

Information about attendees of our live events from sign-in and registration lists.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Name

Mailing Address

Email Address

Telephone Number

Providing attendee statistics to sponsors of the event.

Contacting attendees before or after the event to provide information directly about the event or for promotional purposes as outlined at the time of collection.

Sharing information with event or promotion sponsors, with notification to you when we collect the information

User Generated Content and Public Activities

Comments, recommendations, reader reviews, ratings or any other items that you choose to submit.

INFORMATION COMMONLY COLLECTED

SAMPLE USES OF COLLECTED INFORMATION

Screen Name or Public ID

Images or Photos including Profile Pictures

Public profile details

Comments

Recommendations

Reviews

Ratings

Displaying comments on articles to the public and notifying other participants of your comments.

Displaying your recommendations or reviews to the public alongside or separately from the content or items being reviewed.

Using your public activities to score public opinion – such as using your rating to give an average rating by all reviewers.

If you choose to engage in public activities, you should be aware that any public comments you make can be read, collected and used by other Users. Postmedia is not responsible for the public comments or personal information you disclose in the course of your public activities and assumes no responsibility to publish, take down, remove or edit any of your public activities or submissions. For more information, please see our Terms of Service.

Public activities may also be included in Postmedia’s RSS feeds, APIs and other distribution formats. As a result, you acknowledge that your public activities may appear on other websites, blogs, or feeds. Furthermore, when you share or recommend content on Postmedia’s platform to a third-party platform (such as Facebook, Google+ and Twitter), any information you share will be covered by the respective privacy policy of such third-party platform.

USE OF TECHNOLOGY

How Does Our Technology Monitor Our Properties?

Postmedia’s Properties may place technologies (typically small data files) such as “cookies”, “web beacons”, “tags and scripts”, and local storage objects (“LSOs”) such as HTML5, that websites or applications commonly write to your computer or device and contain information that can help identify you each time you visit one of our Properties. Postmedia uses these technologies to measure website and application activity and traffic patterns, to log your activity, to develop analytics, and to store your reading and behaviour history. If and to the extent that we share any of this information with third-party vendors and advertising networks to deliver advertisements on our Properties, it is shared as Non-Personal Information. Third parties may also place and access these or similar technologies on your devices for the purpose of delivering Customized Experiences such as advertisements directed at your interests. Postmedia does not have access to, nor control over, the use of tracking technologies by such third parties. As such, the placement of these third-party technologies on your computer or devices is subject to the terms, conditions and policies of such third-party vendors and advertising networks. You may choose to set your computer or device to reject these technologies. However, some features available on our Properties may rely on these technologies, and any rejection of the same may impact your ability to use features on our Properties.

How Do You Manage The Use of Advertising Technologies?

Postmedia is a member of the Interactive Advertising Bureau of Canada (IAB Canada) and follows industry standards for online advertising. The majority of advertisements displayed on our Properties are served through one or more reputable third party advertisement-serving companies, including Google. You can control advertising technologies, such as cookies, via the Google Ad and Content Network Privacy Policy. If you are interested in obtaining more information about Customized Experiences in advertising and how you can control technologies that are being placed on your computer or device by other companies, you can visit Google’s “How Google Ads Work” page. Additionally, Postmedia ePaper products (digital versions of our printed newspapers), are maintained by PressReader and are therefore governed by PressReader’s Privacy Policy.

Postmedia’s Properties may contain links to other third party websites for your convenience and information. We are not responsible for the privacy practices or the content of any third party websites.

Political Advertising

Postmedia supports responsible political advertising on our Properties and will accept political ads by all registered Canadian political parties. New in 2019 is the requirement under Bill C-76 requiring digital platforms accepting regulated political advertising to maintain a digital ad registry. Postmedia’s ad registry can be found at adregistry.postmedia.com.

Political party advertisers may run political, election and issue related ads, provided that the political party complies with applicable laws, including campaign and election regulations. Political ads may be static (displayed to all users) or targeted (displayed to some users). Static ads are placed on our Properties and do not change, regardless if the website is refreshed and regardless of who visits that site.

Targeted advertising involves directing political ads towards a group or “segment”, made up of persons who share similar general identifiers or behaviours, but cannot be individually identified. See EXAMPLES OF TYPES OF INFORMATION COLLECTED, STORED AND USED above for the type of information we may collect and use for targeted advertising

Effective on June 14, 2019, if you wish to no longer receive targeted political advertisements, you can opt-out at any time at adregistry.postmedia.com. Please note that if you opt-out, you may still receive non-targeted, static advertisements of a political nature. You may also need to opt-out of tailored advertising delivered by Postmedia from any other device or browser in which you access our Properties.

Ad Blocking

Postmedia helps to fund journalism efforts through the use of advertising. As part of our Terms of Use, Postmedia reserves the right to refrain from providing any service, including access to Postmedia Properties, to Users using ad blocking or other means of circumventing advertisements.

Collection and Use of Usage Information

From time to time, we collect certain usage information from our servers that relates to the use of our Properties. We use this information for statistical analysis and to improve our Properties, for example, by enhancing pages or features that are visited frequently. On occasion, we may share this information with our affiliates or other third party vendors or service providers to provide them with an indication of the amount of interest in our Properties for advertising purposes and to help us plan for technical improvements.

To Whom Do We Disclose Personal Information?

We will share your Personal Information with our affiliates to provide and develop our Properties. We may also combine information internally across the different Properties covered by this Privacy Policy to help our Properties be more relevant and useful to you and others. Postmedia may share your Personal Information with third party service providers in order to enable them to provide services on our behalf. We use third parties to help us provide products and services on our Properties (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform any tasks on our behalf and are obligated not to disclose or use it for other purposes. Some service providers may be located outside of Canada where Personal Information may be subject to the laws of those jurisdictions.

We do not share your Personal Information with any third-party advertisers or ad networks for their own advertising use except for: (i) hashed or device identifiers (to the extent they are Personal Information in some countries); (ii) with your permission or (iii) data already visible to any Users of the Properties. However, if you view or click on an ad on or off our Properties, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of cookies, identify you. Advertising partners can associate Personal Information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith reasons to believe that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Properties (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of our Users, personnel, or others. We attempt to notify Users about legal demands for their Personal Information when appropriate, in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We can also share your Personal Information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your Personal Information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith reasons to believe that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Properties (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of our Users, personnel, or others. We attempt to notify Users about legal demands for their Personal Information when appropriate, in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We can also share your Personal Information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your Personal Information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

How do we retain and safeguard your personal information?

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, and unauthorized access, disclosure, copying, use or modification.

We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any Personal Information that you send us. There is no guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

We process data both inside and outside of Canada and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you and “legitimate interests”.

Where we rely on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and, where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact our Data Protection Officer as listed at the end of this Privacy Policy.

How can you access your personal information?

We will make available to you any Personal Information that we have collected, used or disclosed upon your written request. This includes data that you or others provide to us and data generated or inferred from your use of our Properties. We will attempt to respond to your written request within thirty (30) days. We will advise you in writing if we cannot meet your request within this time limit.

We provide many choices about the collection, use and sharing of your Personal Information, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the Personal Information that we have about you.

For Personal Information that we have about you:

Delete Personal Information: You can ask us to erase or delete all or some of your Personal Information (e.g., if it is no longer necessary to provide products or services to you).

Change or Correct Personal Information: You can edit some of your Personal Information through your account, as applicable. You can also ask us to change, update or fix your Personal Information in certain cases, particularly if it’s inaccurate.

Object to, or Limit or Restrict, Use of Personal Information: You can ask us to stop using all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Information is inaccurate or unlawfully held).

Right to Access and/or Take Your Personal Information: You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form.

We retain your Personal Information even after you have closed your account or terminate a subscription, if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us.

Please check back periodically as the Privacy Policy may be amended from time-to-time. If you continue to use our products or services after we make changes to this Privacy Policy, you are consenting to any updated version of the Privacy Policy. Whenever policy changes are significant, Postmedia will endeavour to provide public notice to you and to archive previous versions of our Privacy Policy.